FD20601800029_Redacted.pdf

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. CONTRACTING ACTIVITY

This Justification and Approval to request authority for Other Than Full and Open Competition supports requirements generated for the Air Force Sustainment Center (AFSC), 638th Supply Chain Management Group (SCMG), 411th Supply Chain Management Squadron (SCMS). The contracting activity for this requirement is Defense Logistics Agency (DLA) Aviation at Robins AFB, GA. The Purchase Request (PR) number supporting this contracting action is FD2060-18- 00029.

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING PROCESSED

The purpose of this requirement is to purchase spares for the following parts in support of the UH-1N Helicopter Program:

Drive Shaft Assembly NSN 1615-01-412-0584 PN 212-340-111-101

Due to the circumstances described herein, the activity requests authority to acquire these spares using Other Than Full and Open Competition as prescribed by FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. This action will result in the award of a new Firm-Fixed Price (FFP), indefinite delivery requirements contract with five one-year ordering periods. Market Research was conducted for this item, which concluded that the following company is the only viable source that can satisfy this agency need:

Kamatics Corporation 1330 Blue Hills Ave.

Bloomfield, CT 06002

CAGE: 50632

Large Business

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED TO MEET AGENCY

NEEDS

The agency’s need is to support and ensure that the operational mission of the UH-1N helicopter program is successfully accomplished as a result of procuring the part identified in this document. The estimated purchase costs, best estimated quantities thereof (per Ordering Period), and aggregated totals for the entire requirement are illustrated in the below table. The Kaflex Main Drive Shaft Assembly is a Flight Safety Critical Item and contains multiple components, which are also Aviation Critical Safety Items (CSIs).

Manufacture of this item requires precision machining and strict quality control of materials, finishes, and processes. Such key characteristics are forgings and raw materials which, according to the engineering drawing, require Kamatics source qualification. The detailed mechanical design of the driveshaft assembly is devised by , subject to the requirements of Bell Helicopter Textron (BHT) Procurement Specification 2 - 40-and applicable referenced specifications, publications, and drawings. The requirements of the Procurement Specification are detailed only to the extent necessary to obtain the desired mechanical characteristics, performance, and permanency of the assemblies. Assemblies furnished in accordance with the Procurement Specification must have passed the specified qualification tests.

Through the Screening Analysis Worksheet process, the Drive Shaft Assembly was designated with an Acquisition Method Code (AMC) of “3”, which indicates that this part must be acquired for the second or subsequent time directly from the actual manufacturer. The Acquisition Method Suffix Code (AMSC) for this part was designated as “B”, this part must be acquired from a manufacturing source specified on a source control or selected item drawing as defined by the current version of DoD-STD-100. Suitable technical data, Government data rights, or manufacturing knowledge are not available to permit acquisition from other sources, nor qualification testing of another part, nor use of a second source part in the intended application.

The total estimated cost for this acquisition is as displayed in the table below.

Each ordering period will contain quantity ranges below and above the Best Estimated Quantity (BEQ). The basis of this requirement is derived from the March 2017 D200A summary computation, which identifies the specific parts that need to be purchased and also calculates (1) the Forecast Unit Price and (2) the quantities that are needed by the Warfighter. The type of funding utilized for this requirement is Consolidated Sustainment Activity Group (CSAG) FY 18-FY22 funding (Appropriation 4930).

Noun: NSN: Part Number: Unit Cost:

BEQ: Totals

Drive Shaft Assembly (Ordering Period 1)

1615-01-412-0584 212-340-111-101 35

Ordering Period 2 1615-01-412-0584 212-340-111-101 15

Ordering Period 3 1615-01-412-0584 212-340-111-101 15

Ordering Period 4 1615-01-412-0584 212-340-111-101 15

Ordering Period 5 1615-01-412-0584 212-340-111-101 15

Estimated Total:

The Government is requesting that the Contractor begin delivery after award of an order at a rate of at least five (5) units per month.

This is required in order to support the UH-1N. The UH-1N is a light-lift utility helicopter used to support various missions. The primary missions include: airlift of emergency security forces, security and surveillance of off-base nuclear weapons convoys, and distinguished visitor airlift.

Other uses include: disaster response operations, search and rescue, medical evacuation, airborne cable inspections, support to aircrew survival school, aerial testing, routine missile site support and transport. The UH-1N is part of the presidential aerial support, along with supporting the Special Operation Forces (SOF)/Search and Rescue Personnel Recovery missions.

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION

10 USC 2304(c)(1), as implemented by FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, required by FAR 6.303-2(b)(4).

V. DEMONSTRATION THAT THE CONTRACTOR’S UNIQUE QUALIFICATIONS

OR NATURE OF THE ACQUISITION REQUIRES THE USE OF THE AUTHORITY

CITED ABOVE (APPLICABILITY OF AUTHORITY)

The contemplated contract will be solicited under “Other Than Full and Open Competition” to Kamatics Corporation as they are the only viable source who possesses the proprietary data necessary to manufacture the subject item. The following paragraphs summarize the respective conclusions, all of which support a sole source requirement to Kamatics.

On 25 July 2017 the Logistics Manager asked Kamatics via email if they would be interested in selling the Government the data rights. On 31 July 2017 Kamatics responded stating they would not sell the proprietary data. The Screening Analysis Worksheet states that “No further action to improve the competitive status of this item will be taken by 429 SCMS/GUMAC.” This conclusion was based on the premise that this proprietary data was to be retained for future business opportunities and interests of the company.

The market research, dated August 2017, conducted for the Drive Shaft Assembly identified only one capable source:

Kamatics Corporation 1330 Blue Hills Ave Bloomfield, CT 06002

CAGE: 50632

POC: Terri-Ann Roberts;

The Market Research concludes that this item was designed by Kamatics Corporation (CAGE:

50632) for use on the military UH-1N. Kamatics was a vendor to BHT providing these items through Government contracts with BHT. BHT was contacted and they declined being able to manufacture and sell this item. They do not have the item in their system anymore and would not be interested in manufacturing this item. Because of this, BHT is excluded as a viable candidate for satisfying this agency need.

The Drive Shaft Assemblies are not commercial off the shelf items. There are no commercial or non-developmental items that meet the Government requirements. The item being procured under this effort is utilized by military only. The Kaflex drive shaft was designed and developed as an independent system specifically for the military UH-1N aircraft after a loss of life incident occurred. In comparison to commercial driveshafts that may be available for the Bell Helicopter commercial UH-1N, significant modifications to the shaft casings and associated hardware would have to be made to the military aircraft to accommodate the commercial drive shaft. The Kaflex drive shaft utilizes self-lubricating couplings with a flex element and a built-in fail safe mechanism, which the commercial UH-1N shafts do not have. The essential physical characteristics of the Kaflex drive shaft is significantly different, and to modify the Bell commercial UH-1N drive shaft to meet the same criteria of the Kaflex drive shaft would cost the Government an extensive amount. Therefore, the Kaflex drive shaft would not be considered a commercial item of-a-type with minor modification.

Any attempts by the Government to reverse-engineer the Drive Shaft Assembly would result in a significant duplication of costs and unacceptable delays that would not be recouped by the AF within the timeframe that this part is anticipated to be utilized on the UH-1N aircraft. To make this determination, the team assessed an analogous project that reverse-engineered the Fuel Quantity Indicator (FQI) for the HH-60G aircraft. This effort required 5 years and to complete. Discussions with Engineering revealed that the Drive Shaft Assembly (although more mechanical in nature than the FQI) is thought to be very similar in technical complexity based on the fact that the Drive Shaft Assembly (being an Aviation Critical Safety Item) would require intensive design and testing in order to reverse-engineer and qualify a substitute. Therefore, for quantitative purposes, we used the FQI reverse-engineering contract as a cost and schedule comparison for correlating a similar effort for the Drive Shaft Assembly. Based on the above assessment by engineering and the program management team, reverse-engineering would require approximately 5 years and in funding. Also, once that is completed, the time required to allocate funding, compete a production contract, and begin receiving assets could potentially add 2 – 3 more years, totaling 8 years (Reverse-engineer = ~5 years;

Compete/Award/Deliver = ~3 years).

Given the above assumptions, which are based on a comparison to the HH-60G FQI reverse-engineering project, the Government will not achieve any cost savings during the life of the UH- 1 helicopter program. The UH-1N fleet is anticipated to begin retiring in 2020; however, a certain date for retirement has not been set as the acquisition for a replacement is just beginning.

The Government expects to purchase approximately 95 drive shaft units during the life of this effort. Forecasts beyond five years is not known at this time due to the unknown anticipated retirement of the UH-1N. It can be concluded that choosing to reverse-engineer the Drive Shaft Assembly would not produce any cost benefit to the AF within the anticipated duration (i.e.

operational years) of service life for the UH-1N helicopter.

In conclusion, the only identified manufacture source through which Operations, Safety, Suitability and Effectiveness (OSS&E), and Configuration Control can be successfully maintained is Kamatics. Accordingly, Kamatics is the only company capable of providing the supplies described in Section III above without the U.S. Air Force experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling its requirements.

VI. DESCRIPTION OF EFFORTS TO ENSURE THAT OFFERS ARE SOLICITED

FROM AS MANY POTENTIAL SOURCES AS DEEMED PRACTICABLE

Sources Sought Synopsis (SSS) was posted on 29 June 2017 under synopsis number FD2060-18- 00029. No vendors responded to the SSS. The Government conducted a market survey to identify potential sources that possess the expertise, capabilities, and experience to meet qualification requirements to manufacture the Drive Shaft Assembly, NSN 1615-01-412-0584, P/N 212-340-111-101, applicable to the UH-1N Helicopter.

VII. DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND REASONABLE

The anticipated cost of this acquisition will be considered fair and reasonable to the Government.

Price analysis will be utilized if possible. The Contractor will be required to provide certified cost or pricing data to support the Government’s evaluation of the proposed cost In Accordance With (IAW) FAR 15.403-4. The proposed cost elements will be negotiated by the Government based on recommendations from the Defense Contract Audit Agency (DCAA)/Defense Contract Management Agency (DCMA), and local technical personnel supporting the program.

VIII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE

RESULTS

Market research was conducted in August 2017 pursuant to FAR 10.001 and 10.002. UH-1N engineers thoroughly assessed the availability (and/or Government ownership) of the required technical data via the Joint Engineering Data Management Information and Control System (JEDMICS) at https://jedmics.af.mil/webjedmics/index.jsp, but for this item, the needed information was clearly proprietary to Kamatics. Also, a Federal Logistics Information search was conducted at the IHS Haystack website at http://www.ihs.com/products/supply-chain/defense/haystack.aspx to determine if the item was available from a different vendor who could serve as an alternate source of supply. Helicopter-related periodicals were searched for potential supply sources. The commercial market was searched using the Small Business Dynamic Search Engine and Google. The NAICS code 332721 and noun drive shaft was used in both search engines. None of these efforts identified additional sources for the manufacture of this item.

IX. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND

OPEN COMPETITION

None.

X. LIST OF SOURCES, IF ANY, THAT EXPRESSED INTEREST IN THE

ACQUISITION

See Section VI above.

XI. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE MAKING

SUBSEQUENT ACQUISITIONS FOR THE SUPPLIES OR SERVICES REQUIRED

The U.S. Government does not have the technical data required for manufacturing these items.

This data would have enabled other companies to fulfill the Government's requirements, thus fostering competition; however, the Government has been unable to garner the willingness from the OEM to part with their intellectual property for these parts. As a result, data is not available to award this effort to any other source. Due to the AF not owning the required technical data for these parts, it is not possible to approve any additional sources of manufacture because of the inability to verify and validate another source’s capabilities for meeting this agency need.

However, the Government will (1) conduct market surveillance through the monitoring of technical literature every 18 months, (2) explore alternative product support strategies with the pertinent engineering organizations, and (3) continue inquiring with industry for potential sources of supply and/or opportunities to purchase the needed intellectual property needed to qualify additional sources. Future requests for purchasing data rights will be coordinated with the OEM’s leadership to ensure that these company positions are aligned with their true business objectives and not simply a default response. Should the Contractor respond with a proposal for data, the Logistics Manager in AFSC will work with the System Program Office (SPO) in AFLCMC to budget for the funds to procure data where it makes economic sense to do so.

XII. CONTRACTING OFFICER’S CERTIFICATION

As evidenced by my signature, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. TECHNICAL/REQUIREMENTS PERSONNEL’S CERTIFICATION

As evidenced by their signatures, the technical and/or requirements personnel have certified that any supporting data contained herein, which is their responsibility, is both accurate and complete.